Your Privacy Matters

Privacy Policy

Last updated: 17 December 2024

About this Policy

This Privacy Policy explains how Vertial Holdings Pty Ltd (ABN 72 629 494 926) ("Trvel", "we", "us", or "our") collects, uses, discloses, and protects your personal information. We are committed to protecting your privacy in accordance with the Australian Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs), as well as applicable privacy laws in jurisdictions where we operate.

1. Information We Collect

1.1 Information You Provide

When you use our services, we may collect:

  • Contact Information: Email address, name (if provided)
  • Payment Information: Payment card details are processed securely by our payment processor (Stripe) and are not stored on our servers
  • Order Information: Destination country, plan selected, purchase date
  • Communications: Messages you send to our support team

1.2 Information Collected Automatically

When you visit our website, we automatically collect:

  • Device Information: Browser type, operating system, device type
  • Usage Information: Pages visited, time spent on pages, referral source
  • Technical Information: IP address, general location (country/region level)

1.3 Cookies and Similar Technologies

We use cookies and similar technologies to improve your experience, analyse site traffic, and understand how our services are used. You can control cookies through your browser settings. Essential cookies are required for the website to function properly.

2. How We Use Your Information

We use your personal information to:

  • Process and fulfill your eSIM orders
  • Send order confirmations and eSIM delivery via email
  • Provide customer support and respond to enquiries
  • Process refunds and handle disputes
  • Improve our products and services
  • Comply with legal obligations
  • Detect and prevent fraud

3. Legal Basis for Processing

We process your personal information based on:

  • Contract Performance: To fulfill our obligations when you purchase from us
  • Legal Obligations: To comply with applicable laws and regulations
  • Legitimate Interests: To improve our services and prevent fraud
  • Consent: Where you have given explicit consent (e.g., marketing communications)

4. Information Sharing and Disclosure

We may share your information with:

  • Service Providers: Third parties who help us operate our business, including:
    • Payment processors (Stripe)
    • Email service providers
    • eSIM infrastructure providers (for order fulfillment only)
    • Analytics providers
  • Legal Requirements: When required by law, court order, or government request
  • Business Transfers: In connection with a merger, acquisition, or sale of assets

We do not sell, rent, or trade your personal information to third parties for their marketing purposes.

5. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. We ensure appropriate safeguards are in place to protect your information in accordance with applicable data protection laws.

For customers in the European Economic Area (EEA) or United Kingdom, we ensure transfers are made using appropriate safeguards such as Standard Contractual Clauses approved by relevant authorities.

6. Data Security

We implement appropriate technical and organisational measures to protect your personal information, including:

  • Encryption of data in transit (TLS/SSL) and at rest
  • Secure payment processing through PCI-compliant providers
  • Regular security assessments and updates
  • Access controls and authentication measures
  • Employee training on data protection

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including:

  • Order records: 7 years (for tax and accounting purposes)
  • Support communications: 2 years after resolution
  • Marketing preferences: Until you withdraw consent
  • Website analytics: 26 months

8. Your Rights

Depending on your location, you may have the following rights:

  • Access: Request a copy of your personal information
  • Correction: Request correction of inaccurate information
  • Deletion: Request deletion of your personal information
  • Portability: Request your data in a portable format
  • Objection: Object to certain processing activities
  • Withdrawal: Withdraw consent where processing is based on consent

To exercise these rights, please contact us at privacy@trvel.co. We will respond to your request within 30 days (or sooner where required by law).

8.1 Australian Residents

Under the Privacy Act 1988 (Cth), you have the right to access and correct your personal information. If you believe we have breached the Australian Privacy Principles, you may lodge a complaint with us or the Office of the Australian Information Commissioner (OAIC).

8.2 UK and EEA Residents

Under the UK GDPR and EU GDPR, you have additional rights including the right to lodge a complaint with your local supervisory authority (e.g., the Information Commissioner's Office in the UK).

8.3 Singapore Residents

Under the Personal Data Protection Act 2012 (PDPA), you have rights regarding access and correction of your personal data. You may contact us or the Personal Data Protection Commission (PDPC) regarding your data protection concerns.

9. Children's Privacy

Our services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children. If you become aware that a child has provided us with personal information, please contact us immediately.

10. Third-Party Links

Our website may contain links to third-party websites. We are not responsible for the privacy practices of these websites. We encourage you to review the privacy policies of any third-party sites you visit.

11. Marketing Communications

We will only send you marketing communications if you have opted in to receive them. You can unsubscribe at any time by clicking the "unsubscribe" link in any marketing email or by contacting us directly.

12. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on our website with a new "Last Updated" date. Your continued use of our services after any changes indicates your acceptance of the updated policy.

13. Contact Us

If you have questions, concerns, or complaints about this Privacy Policy or our data practices, please contact us:

Vertial Holdings Pty Ltd

ABN: 72 629 494 926

Email: privacy@trvel.co

New South Wales, Australia

For Australian privacy complaints that are not resolved to your satisfaction, you may lodge a complaint with the Office of the Australian Information Commissioner: